MEMORANDUM OF UNDERSTANDING 

BETWEEN 

THE U.S. DEPARTMENT OF ENERGY 

AND 

THE U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 

I. INTRODUCTION 

This Memorandum ofUnderstanding (MOU) serves to set forth the authorities, responsibilities, 

and procedures by which the U.S. Department ofEnergy (DOE) and the U.S. Department of 

Health and Human Services (HHS) will conduct statutorily mandated activities required to 

assist with claims processing under the Energy Employees Occupational Illness Compensation 

Program Act of 2000 (EEOICP A). EEOICPA provides for timely, uniform, and adequate 

compensation of covered employees and, where applicable, survivors ofsuch employees 

suffering from illnesses incurred by such employees in the performance of duty. 

DOE and HHS (hereunto, "Parties") will make every effort to ensure that activities 

conducted under this MOU, as well as those conducted through other mechanisms, are 

coordinated, non-duplicative, and supportive of a fair and timely compensation program for 

these workers and their survivors. 

II. BACKGROUND 

EEOICPA, 42 U.S.C. §§ 7384 et seq., establishes a compensation program to provide 

lump-sum payments and medical benefits as compensation to covered employees suffering from 

designated illnesses that occurred as a result oftheir exposure to radiation, beryllium, or silica 

while in the performance of duty for DOE and certain ofits vendors, contractors, and 

subcontractors. This law also provides for compensation payments to certain survivors of 

covered employees. In the Ronald W. Reagan National Defense Authorization Act for Fiscal 

Year 2005, Public Law 108-375 (codified as amended in scattered sections oftitle 42 ofthe 

U.S.C.), Congress abolished Part D ofEEOICPA and created a new Part E in its place. Part E 

established a new system ofFederal payments for employees ofDOE contractors and 

subcontractors, or their eligible survivors, who develop an illness due to exposure to toxic 

substances at certain DOE facilities. 

EEOICPA instructed the President to carry out the compensation program through one or more 

Federal Agencies or officials as designated by the President. Pursuant to this statutory provision, 

the President issued Executive Order (E.O.) 13179, Providing Compensation to America's 

Nuclear Weapons Workers, which assigned primary responsibility for administering the 

compensation program to the Department ofLabor. This E.O. assigned certain specific 

responsibilities to HHS and DOE that are enumerated in other sections ofthis MOU. EEO ICPA 

also instructed the President to establish and appoint an Advisory Board on Radiation and 

Worker Health (ABRWH or Advisory Board). 

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III. PURPOSE 

This MOU sets forth the guidelines for collaboration between DOE and HHS in carrying out 

their respective responsibilities under EEOICPA and E.O. I 3179. This MOU is not intended to 

affect existing MOUs and Interagency Agreements (IA) between DOE and HHS or to preclude 

DOE and HHS from entering into MOUs and IAs for other purposes. 

IV. AUTHORITIES 

This MOU is consistent with, and is entered into, under the authority ofEEOI CPA and 

E.O. 13179. 

V. RESPONSIBILITIES 

A. General - Executive Order 13179 

The responsibilities assigned to HHS by E.O. 13179 that are relevant to actual or potential 

interactions between DOE and HHS are as follows: 

1. Promulgate regulations establishing: 

(a) guidelines to assess the likelihood that an individual with cancer sustained the cancer in 

the performance of duty at a DOE facility or an atomic weapons employer (AWE) facility 

(42 CFR part 81, Guidelines for Determining the Probability ofCausation under 

EEOJCPA); and 

(b) methods for arriving at, and providing reasonable estimates of, the radiation doses 

received by individuals applying for assistance under EEOICPA for whom there may be 

inadequate records ofradiation exposure (42 CFR part 82, Methods/or Radiation Dose 

Reconstruction under EEOICPA). 

2. Develop and implement procedures for considering and issuing determinations on petitions 

by classes of employees to be treated as members ofthe Special Exposure Cohort (SEC) 

(42 CFR part 83, Proceduresfor Designating Classes ofEmployees as Members ofthe 

Special Exposure Cohort under EEOICP A). 

3. With the assistance of DOE, apply the methods developed under l .(b) above to estimate the 

radiation doses received by individuals applying for assistance under EEOICPA. 

4. Provide ABRWH with administrative services, funds, facilities, staff, and other necessary 

supp01i services to catTy out its functions under EEOI CPA and in accordance with the 

Federal Advisory Committee Act, as amended (5 U.S.C. App.). 

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The responsibilities assigned to DOE by E.O. 13179 that are relevant to actual or potential 

interactions between DOE and HHS are as follows: 

1. Provide HHS and ABRWH access, in accordance with law, to all relevant information 

pertaining to worker exposures, including access to restricted data, and any other technical 

assistance needed to ca1Ty out their responsibilities. 

2. Upon request from HHS, and as pennitted by law, require a DOE contractor or 

subcontractor to provide information relevant to a claim under EEO I CPA. 

3. Designate and list A WEs and beryllium vendors pursuant to EEO I CPA and update these lists 

as required. 

B. HHS Responsibilities 

1. Identification of Data Needs 

HHS, through the National Institute for Occupational Safety and Health (NIOSH), will 

evaluate and identify the data, documents, and information that are relevant and necessary for 

canying out its responsibilities under EEOICPA, including estimating radiation doses for 

individual-covered employees with cancer, evaluating petitions by classes of employees for 

inclusion in the SEC, and evaluating residual contamination at A WEs and beryllium vendors. 

In conducting these activities, HHS will strive for efficiency in collecting dose reconstruction 

information from DOE and its site contractors. To accomplish this goal, HHS will search 

relevant in-house data sources to ensure that requests for access to necessary information are not 

duplicative. HHS will request from DOE only the data and information HHS believes are 

relevant to individual worker claims to conduct dose reconstruction or evaluate SEC petitions. 

In addition, as feasible, without delaying the individual dose reconstruction process and the 

consideration of SEC petitions, HHS will work with DOE to identify pertinent existing 

databases and general information needs relevant for entire processes, buildings, employment 

groups, or facilities. This approach of first using HHS-held data and information and then 

collecting individualized data and, in parallel, seeking general and group data will facilitate 

timely and cost-efficient dose reconstructions and evaluation of SEC petitions. It is expected 

that this approach will best enable the expeditious accretion of information and diminish the 

impact on DOE and HHS resources over time. 

The types of individual, group-based, or general information that may be relevant to HHS' 

responsibility include, but are not limited to, the following: 

I. Individual worker-monitoring data, such as dosimeter readings and bioassay sample results; 

2. Employment history for individual workers; 

3. Group worker-monitoring data; 

4. Workplace area-monitoring data; 

5. Process description information and process history; 

6. Incident, safety, and accident reports; 

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7. Pertinent excerpts from employee medical records; 

8. Information on the quantity and composition ofradioactive substances, including the 

chemical form, particle size distribution, level of containment, and likelihood of 

dispersion; and 

9. Identification, last known address, and phone numbers ofcurrent and former 

supervisors, occupational safety and health staff, and nonsupervisory employees of 

DOE and its contractors, subcontractors, and AWEs with expertise on items 1-8 above. 

A more complete list of information types that may be necessary and relevant for 

reconstructing doses and evaluating SEC petitions is shown in Table 1, below. HHS is 

responsible for determining what data and information are necessary for completing dose 

reconstructions and evaluating SEC petitions and for responding to issues raised by the 

ABR WH and the Centers for Disease Control and Prevention (CDC) contractors. 

HHS will be responsible for the management of all data collected by HHS employees and 

contractors, including data obtained from DOE and its contractors. HHS employees and 

contractors will safeguard all data in accordance with the DOE Office ofEnvironment, Health, 

Safety and Security's (AU) Security Plan for EEOICPA dated May 10, 2017, HHS Policy for 

Information Technology (IT) Security and Privacy Incident Reporting and Response, CDC 

Collateral National Security Information Storage and Briefing/Conference Sites Standard 

Operating Procedure, and certain DOE Directives pertaining to accessing, safeguarding, and 

transmitting classified, Unclassified Controlled Nuclear Information (UCNI), and provisions 

ofthe Privacy Act. Should HHS have a question concerning the proper handling of a 

particular document or class of documents, HHS will consult with the DOE Headquarters 

(HQ) Security Coordinator. 

HHS amended its Privacy Act Systems of Records for an existing NIOSH System of 

Records, 09-20-0147, Occupational Health Epidemiologic Studies - HHS/CDC/NIOSH, on 

August 15, 2002, and September 29, 2003, to add new routine uses required to carry out 

EEOICPA responsibilities and to revise the system name. Furthermore, HHS published a 

Notification of Proposed Altered System ofRecords for the NIOSH System ofRecords, 

09-20-0 l 4 7, Occupational Health Epidemiological Studies and EEOICP A Program 

Records, on May 27,2011, and issued further clarifications dated June 14, 2011, regarding 

the routine use and retention of EEO I CPA records. 

2. Security Clearances 

HHS personnel and contractors with appropriate security clearances will review documents 

and data deemed by HHS to be relevant and necessary for carrying out HHS 

responsibilities under EEOICP A. HHS will expedite completion of necessary applications 

for appropriate security clearances to facilitate DOE's clearance determinations and permit 

entry to DOE and DOE-owned, contractor-operated facilities. HHS will be responsible for 

costs associated with new investigations and reinvestigations for HHS Federal and 

contractor employees requiring a DOE security clearance. NIOSH will collaborate with 

CDC, HHS, and DOE HQ Security Coordinator to track and facilitate security clearance 

investigations, reinvestigations, verifications, transfers, rep01table incidents, and security 

terminations for NIOSH employees and contractor staff. 

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3. Review of Documents for Classified and Controlled Information 

HHS will send to the DOE HQ Security Coordinator documents that HHS identifies as 

necessary to carry out its responsibilities under EEOICPA for appropriate classification 

review in accordance with DOE policy and the requirements outlined in the DOE Security 

Plan for EEOICPA that was developed in collaboration with NIOSH/Division of 

Compensation Analysis and Support (DCAS). HHS will collaborate with DOE in the 

resolution of security issues. 

4. Protection of Personally Identifiable Information 

Information determined to be Personally Identifiable Information (PII) must be protected in 

accordance with relevant statutes, Office of Management and Budget (0MB) guidelines, 

and HHS regulations and policies. HHS will follow the HHS Privacy Act regulations, 

45 CFR part 5b, Privacy Act Regulations, and HHS governing policies regarding PII. 

For this MOU, all parties agree that PII must be protected in accordance with the Privacy Act 

of 1974, 0MB Circular No. A-130, Managing Federal Information as a Strategic Resource, 

and each Party's regulations and policies. Transmission of data between the Parties will be 

in accordance with agreed-upon protocols which will, at a minimum, include the following 

requirements: 

1. Data stored on removable media (CD, DVD, USB Flash Drives, etc.) must be protected 

using encryption products that are certified pursuant to Federal Information Processing 

Standard (FIPS) 140-2, Security Requirements/or C,yptograph;c Modules. 

2. Passwords used in conjunction with FIPS 140-2 ce1tified encryption must meet the 

current DOE password requirements. 

3. Transmission of removable media must be sent by express overnight service with 

signature and tracking required. 

4. Data files containing PII that are being sent by e-mail must be encrypted with FIPS 

140-2 certified encryption products. 

5. Passwords used to encrypt data files must be sent separately from the encrypted data 

file; i.e., separate e-mail, telephone call, or separate letter. 

6. Websites established for the submission ofinformation that includes PII must use FIPS 

140-2 certified encryption methods. 

7. Remote access to systems and databases that contain PII must use two-factor 

authentication for logon access control. 

8. In addition to other reporting requirements, the loss, or suspected loss, of PII must be 

reported immediately upon discovery to the DOE Joint Cybersecurity Coordination Center 

(JC3) and the HHS NIOSH/DCAS, which will, in turn, notify the HHS PII Breach 

Response Team. 

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5. Requesting Data from DOE 

HHS will direct requests for exposure information necessary to conduct dose reconstructions 

or evaluate SEC petitions to DOE or other points of contact identified by DOE. These 

requests will identify the specific type(s) of information needed and, if appropriate, the 

identity of the employee(s) whose records are needed. These requests will indicate that a 

timely response is needed; and if more than 60 days are required to provide the requested 

information, DOE will notify HHS promptly. 

HHS will provide to DOE and each designated point of contact a status report describing the 

number of requests sent, number of responses received to date, and a listing of any requests 

that are outstanding. This rep01i will also identify the status of followup requests for 

infom1ation. 

6. Official Point of Contact 

HHS designates the following individual as the official point of contact for this MOU: 

Name: Mr. Stuart L. Hinnefeld 

Title: Director, Division of Compensation Analysis and Support 

National Institute for Occupational Safety and Health 

Address: 1090 Tusculum A venue 

Cincinnati, Ohio 45226-1938 

Telephone: (513) 533-6835 

C. DOE Responsibilities 

1. Provision of Data to HHS 

Upon request by HHS and consistent with applicable law, DOE will provide HHS and HHS 

contractors with access to, and copies of, data, documents, and information deemed by HHS to 

be relevant and necessary for carrying out its responsibilities under EEOICPA, including 

estimating radiation doses for individual-covered employees with cancer, evaluating petitions 

by classes of employees for inclusion in the SEC, and evaluating residual contamination at 

A WEs and beryllium vendors. This access includes access to "Restricted Data," as defined in 

the Atomic Energy Act of 1954, as amended (42 U.S.C. § 2014(y)). 

DOE will provide HHS with data and information of the types described in section B.1., 

above, and Table 1, below, as needed and where such information exists, to enable HHS to 

process cun-ent individual dose reconstructions and SEC class petitions and to achieve more 

timely and cost-effective processing offuture dose reconstructions and SEC class petitions. 

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The primary strategy for achieving such increased timeliness and cost-effectiveness will be to 

provide HHS with information and records on a process, building, employment group, or 

facility-wide basis, which will gradually reduce, but not eliminate, the need for HHS to 

request information and records on a case-by-case basis for dose reconstructions and SEC 

class petitions at the time they are being processed. 

Parties will adhere to the guidance outlined in the DOE Security Plan for EEOICPA that 

describes and establishes processes for requesting data, security clearances, site access, and 

resolution ofsecurity issues. The Security Plan for EEOICP A is an effort to balance the need 

for protecting classified and controlled unclassified information with the need to fairly 

adjudicate compensation claims. Revisions to the Security Plan for EEOICPA may be 

required due to changes in governmental security requirements, operational experience, or 

unexpected events. 

Parties acknowledge that, while all the material in section B.1., above, and Table 1, below, is 

potentially relevant to each claim, the actual data necessary will vary among claims. Paiiies 

also recognize that information about worker exposures will vary from site to site. Paiiies will 

work cooperatively to coordinate research and data retrieval activities to assist in an efficient 

and effective claims process. 

DOE has established a Privacy Act System of Records, which includes the necessary 

routine uses required to cany out EEOICPA responsibilities for the following system of 

record: 

1. DOE-! 0, Energy Employees Occupational Illness Compensation Program Act Files. 

DOE has amended certain Privacy Act Systems of Records to include new routine uses 

required to carry out EEOICPA responsibilities for the following systems ofrecords: 

1. DOE-5, Personnel Records ofFormer Contractor Employees; 

2. DOE-33, Personnel Medical Records; 

3. DOE-35, Personnel Radiation Exposure Records; 

4. DOE-38, Occupational and Industrial Accident Records; 

5. DOE-7 1, The Radiation Accident Registry; 

6. DOE-72, The Department ofEnergy Radiation Study Registry; 

7. DOE-73, The US-DTP A Registry; and 

8. DOE-88, Epidemiologic and Other Health Studies, Surveys andSurveillances. 

DOE maintains a moratorium on the destruction of records that may be useful for 

epidemiological purposes, and under that moratorium will continue to maintain any records 

that are needed for dose reconstruction and SEC petition consideration. DOE will coordinate 

any status changes or requests for deviations (i.e., destruction of records under the 

moratorium) with HHS prior to taking any official DOE actions in this regard. 

For the purpose of independently reviewing any records, information, or data that HHS 

determines are relevant and necessary for carrying out its responsibilities under EEOICPA, 

and as consistent with applicable laws, DOE will allow HHS personnel, HHS contractors, and 

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members ofthe Advisory Board with appropriate clearances access to DOE and DOE-owned, 

contractor-operated facilities. Consistent with applicable laws and regulations, DOE will 

provide HHS personnel and contractors copies of all records, information, or data deemed 

relevant by HHS. Based on the requirements ofEEOICPA, DOE will provide copies of 

records, information, and data in a timely manner. 

Upon request by HHS, DOE will provide certification that record searches requested by HHS 

have been completed. Although DOE will work to provide comprehensive responses to HHS 

requests, additional information relevant to a claim may be identified at a later date. When 

DOE identifies such additional information, DOE will promptly notify HHS that the new 

information has been found and also send HHS the additional information. 

2. Classification of Documents and Security Clearances 

DOE and its contractors will continue to perfo1m timely classification reviews of documents 

and data necessary for HHS to caiTy out its responsibilities under EEOICP A in accordance 

with DOE policy and the DOE Security Plan for EEO I CPA. DOE will provide to HHS an 

estimated timeframe for completing any necessary classification reviews of requested 

documents. HHS personnel, HHS contractors, and members ofthe Advisory Board who have 

appropriate security clearances will, in the course of carrying out their responsibilities under 

EEOICPA, be permitted to review classified and controlled documents and data to identify 

those that are needed to carry out HHS responsibilities under EEOICP A. DOE will, wherever 

possible and in a timely manner, declassify, downgrade the classification, or redact the 

classified or otherwise controlled information in these documents and data. Parties have 

established procedures to address those documents and data that cannot be declassified, but 

may be necessary to complete dose reconstructions or SEC petition considerations. DOE will 

assist HHS personnel, including Advisory Board members, and contractors in obtaining 

appropriate security clearances. 

3. Protection of Personally Identifiable Information 

Information determined to be PII must be protected in accordance with relevant statutes, 

0MB guidelines, and DOE regulations and policies. Some DOE requirements and guidance 

are promulgated through DOE departmental regulations, orders, and manuals, which are 

available at http://www.directives.doe.gov/. DOE has established requirements for the 

protection of PII in accordance with the Privacy Act of 197 4 and 0MB requirements. 

Specifically, PII information provided by the U.S. Government or other U.S. Government 

contractors for use in the execution ofwork under this MOU must be protected in accordance 

with 10 CFR part 1008, Records Maintained on Individuals (Privacy Act); DOE Order 206.1, 

Department ofEnergy Privacy Program; DOE O 473.3A, Protection Program Operations; 

DOE 4 70.6, Technical Security Program; and DOE 205.1 B, Department ofEnergy Cyber 

Security Program. 

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For this MOU, all parties agree that PII must be protected in accordance with the Privacy Act 

of 1974, 0MB guidance, and each Party's departmental policies. Transmission of data 

between pa11ies will be in accordance with agreed-upon protocols, which will, at a minimum, 

include the following requirements: 

1. Data stored on removable media (CD, DVD, USB Flash Drives, etc.) must be protected 

using encryption products that are certified pursuant to FIPS 140-2. 

2. Passwords used in conjunction with FIPS 140-2 certified encryption must meet the 

current DOE password requirements. 

3. Transmission ofremovable media must be sent by express overnight service with 

signature and tracking required. 

4. Data files containing PII that are being sent by e-mail must be encrypted with FIPS 

140-2 ce11ified encryption products. 

5. Passwords used to encrypt data files must be sent separately from the encrypted data 

file; i.e., separate e-mail, telephone call, or separate letter. 

6. Web sites established for the submission of information that includes PII must 

use FIPS 140-2 certified encryption methods. 

7. Remote access to systems and databases that contain PII must use two-factor 

authentication for logon access control. 

8. In addition to other reporting requirements, the loss, or suspected loss, of PII must be 

reported immediately upon discovery to the DOE JC3 and the HHS NIOSH/DCAS, which 

will, in turn, notify the HHS PII Breach Response Team. 

4. Provision of Other Technical Assistance to HHS 

DOE will provide assistance to HHS, upon request, in identifying and accessing information 

needed to reconstruct radiation doses and evaluate petitions from classes of workers to be 

included in the SEC, for claims and petitions received from current and former employees, 

and survivors of DOE and A WE facilities. Other technical assistance will be provided to 

HHS, upon request, to aid in the development of strategies to identify and prioritize for study 

DOE/A WE or beryllium vendor facilities where significant contamination may have remained 

after activities relating to the production of nuclear weapons were discontinued. 

5. Timeliness of Provision of Information and Technical Assistance 

DOE recognizes that time is of the essence in terms ofproviding information to HHS. DOE 

will provide all requested information to HHS in a timely and efficient manner. If the 

requested information cannot be provided in a timely manner, DOE will provide whatever 

portion of the requested information is available, as well as an estimate of when the remaining 

information will be produced. Following transmission of this estimate, DOE will continue to 

work to provide all requested information to HHS as quickly as possible, unless HHS notifies 

DOE that the remaining information is not required. 

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6. DOE Contractor and A WE Communication and Assistance 

DOE will work with its current and fmmer contractor community and other relevant parties, 

such as A WEs, to facilitate access to information and records needed by HHS. Parties will 

work together to develop clauses to be added to agreements with DOE contractors to ensure 

that DOE contractors collect and maintain infmmation needed to carry out DOE obligations 

under this MOU, and that HHS and its agents have the necessary access to that information. 

7. Official Point of Contact 

DOE designates the following individual as the official point of contact for this MOU: 

Name: Patricia R. Worthington, PhD 

Title: Director 

Address: Office of Health and Safety 

Office of Environment, Health, Safety and Security 

Room B-221/GTN 

U.S. Department of Energy 

1000 Independence A venue, SW 

Washington, DC 20585 

Telephone: (301) 903-5926 

Fax: (301) 903-3445 

VI. DISPOSITION OF RECORDS 

Each Party is to be responsible for the disposition of records in its possession in accordance 

with its own records retention authorities. 

VII. RESPONDING TO FREEDOM OF INFORMATION ACT REQUESTS 

Determinations regarding release of information exchanged pursuant to this MOU that is 

responsive to a valid request under the Freedom of Information Act (FOIA), 5 U.S.C. § 552, 

will be made by the Party from which the information originated. 

VIII. DURATION 

This MOU, effective when signed by the Parties, shall initially remain in effect through fiscal 

year 2024. The Parties' cmTent intent is to renew this agreement at that time. 

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IX. MODIFICATION OR CANCELLATION 

This MOU, or any ofits specific provisions, may be cancelled or amended by mutual, written 

agreement ofthe Parties at any time. Cancellation of this MOU may be accomplished by a 

90-day advanced, written notification by either HHS or DOE to the other Party. 

X. RESPONSIBLE OFFICIALS 

U.S. DEPARTMENT OF ENERGY U.S. DEPARTMENT OF HEALTH 

AND HUMAN SERVICES 

By: 

Patricia R. Worthington, PhD 

Director Director 

Office ofHealth and Safety Division ofCompensation Analysis 

Office ofEnvironment, Health, Safety and Suppott 

and Security National Institute for Occupational 

Safety and Health 

Date: Date: I I I I I 

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[Signature on File]

[Signature on File]
Table 1 

Examples of Potentially Relevant Information for Reconstructing Doses 

and Evaluating Special Exposure Cohort Petitions 

The National Institute for Occupational Safety and Health considers the following types of 

information to be potentially relevant in conducting dose reconstructions and evaluating petitions 

from classes of workers for inclusion in the Special Exposure Cohort (SEC). The necessity and 

availability of this information is expected to vary substantially from case to case, and this is not 

an exhaustive list of all information that may be required for the U.S. Department of Health and 

Human Services (HHS) to perform its duties under the Energy Employees Occupational Illness 

Compensation Program Act. HHS will attempt to target its requests to those records necessary 

for specific dose reconstructions or SEC petition evaluations. 

Worker-Monitoring Data 

1. External dosimetry data, including external dosimeter readings (film badge, TLD, 

neutron dosimeters); and 

2. Pocket ionization chamber data. 

Internal Dosimetry Data 

1. Urinalysis results~ 

2. Fecal sample results; 

3. In vivo measurement results; 

4. Incident investigation reports; 

5. Breath radon and/or thoron results; 

6. Nasal smear results; and 

7. External contamination measurements. 

Monitoring Program Data 

1. Analytical methods used for bioassay analyses; 

2. Performance characteristics of dosimeters for different radiation types; 

3. Historical detection limits for bioassay samples and dosimeter badges; 

4. Bioassay sample and dosimeter collection/exchange frequencies; and 

5. Documentation of recordkeeping practices used to censor data and/or administratively 

assigned dose. 

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Workplace-Monitoring Data 

1. Surface contamination surveys; 

2. General area air-sampling results; 

3. Breathing zone air-sampling results; 

4. Radon- and/or thoron-monitoring results; 

5. Area radiation survey measurements (beta, gamma, and neutron); and 

6. Fixed location dosimeter results (beta, gamma, and neutron). 

Workplace Characterization Data 

Information on the external exposure environment, including radiation type (gamma, x-ray, 

neutron, beta, other charged particle); radiation energy spectrum; uniformity of exposure 

(whole-body vs. partial-body exposure); irradiation geometry; and work-required medical 

screenmg x-rays. 

Information Characterizing Internal Exposure 

1. Radionuclide(s) and associated chemical forms; 

2. Results of particle-size distribution studies; and 

3. Respiratory protection practices. 

Process Descriptions 

I. General description ofthe process; 

2. Characterization of the source term (i.e., the radionuclide and its quantity); 

3. Extent of encapsulation; 

4. Methods of containment; and 

5. Other information used to assess the potential for airborne dispersion. 

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